Applied Behavioral Analysis Services (ABAS)

ABAS Compliance Program

Policies, standards, and program documents
REG-005

Compliance Obligations Register

Version 1.0Approved by Compliance Officer · 2026-08-20Review cycle: Annual

Instructions for Use

This register is ABAS's single consolidated definition of its recurring compliance obligations: what is owed, on what cadence or trigger, by which role, and where the evidence lands. Each obligation carries a stable identifier (OBL-NNN) and names its governing source.

What the register does and does not hold. The register defines obligations. Scheduling, due dates, completion records, and evidence artifacts are operational state and live in the Company's compliance management system, which ingests this register. Live state never prints here.

Scope. The register holds obligations that recur on a calendar cadence and obligations triggered by ordinary business events (hire, engagement, termination, policy revision, disclosure-triggering change). Incident-response clocks are procedures and live in their governing documents: SOP-002 for breach response, POL-003-SOP for ticket and grievance response.

How to use this register:

  1. Read each row's source before performing the obligation. The row is the index. The governing document carries the full requirement.
  2. When a policy, SOP, or authority adds, changes, or retires a recurring obligation, revise this register in the same cycle. A row is never edited in the operational system alone.
  3. Retired obligations keep their identifier with a Retired status. Identifiers are never reused.
  4. Payer revalidation and recredentialing cycles vary by payer. The row defines the obligation; each payer's confirmed cycle is recorded in the compliance management system when it is confirmed.

Obligations Register

Monthly

ID Obligation Owner Source Evidence and location
OBL-001Re-screen all current employees and active contractors against the LEIE, SAM.gov exclusions, and state Medicaid exclusion listsHuman ResourcesPOL-011Screening records, compliance program files
OBL-002Re-screen all active vendors against the same three listsDirector of OperationsPOL-011; REG-002REG-002 exclusion-screening record
OBL-003Verify the anonymous reporting channel end to end with a test submissionCompliance OfficerThis registerTest verification record, compliance program files

Quarterly

ID Obligation Owner Source Evidence and location
OBL-004Hold the Compliance Committee meeting and record minutesCommittee ChairPOL-002CFM-001 minutes, compliance program files
OBL-005Submit the Committee's written summary to the Executive Director within 10 business days of each meetingCommittee ChairPOL-002Summary on file, compliance program files
OBL-006Submit the Compliance Officer's written report to the Committee and Executive Director, including training completion rates and open gapsCompliance OfficerPOL-001; TRN-001Report on file, compliance program files

Annual

ID Obligation Owner Source Evidence and location
OBL-007Run the CORI cycle: refreshed acknowledgment form and re-check for every employeeHuman ResourcesPOL-017HRIS acknowledgments; iCORI records
OBL-008Review active vendor and referral-source arrangements, with Executive Director signatureCompliance Officer; Executive DirectorPOL-005REG-002 review fields
OBL-009Re-review any active physician arrangementsCompliance OfficerPOL-007REG-002; compliance program files
OBL-010Audit credential records and a sample of personnel files; report to the CommitteeCompliance OfficerPOL-010; REG-001Audit report, compliance program files
OBL-011Develop or update the annual compliance work planCompliance OfficerPOL-001Work plan, compliance program files
OBL-012Review the Compliance Officer charterCompliance OfficerPOL-001Revision history
OBL-013Review the Compliance Committee charterCompliance CommitteePOL-002Minutes; revision history
OBL-014Review the Code of ConductCompliance OfficerCOC-001Revision history
OBL-015Review the gift and courtesy limit against current OIG nominal-value guidanceCompliance OfficerSTD-001Revision history
OBL-016Review every published controlled document on its review cycleDocument ownerDocument control recordRevision history per document
OBL-017Deliver compliance refresher training to all employees, plus role-specific modulesTraining Coordinator; Compliance OfficerTRN-001Training completion record
OBL-018Re-acknowledge the Code of Conduct across the entire workforceCompliance OfficerCOC-001Acknowledgment records, HRIS
OBL-019Run the conflict-of-interest disclosure cycle, including no-conflicts attestations, and report the summary to the CommitteeCompliance Officer; Human ResourcesPOL-009CFM-002 forms; CFM-004 log; summary report
OBL-020Distribute HR-001 with the CFM-008 acknowledgment on the fixed campaign date; confirm completenessHuman Resources; Compliance OfficerHR-001; CFM-008HRIS acknowledgment records; campaign report
OBL-021Re-issue the PFML workforce notice on the fall DFML rate announcement, effective January 1Human ResourcesCFM-006HRIS acknowledgment capture
OBL-022Complete at least 8 hours of Compliance Officer continuing educationCompliance OfficerPOL-001; PER-001CE certificates, personnel file
OBL-023File the calendar year's breach log with HHS within 60 days after the year endsPrivacy & Security OfficerPOL-014; SOP-002Portal filing record; breach log
OBL-024Review the written information security program and refresh the risk analysisPrivacy & Security Officer201 CMR 17.00Risk analysis record, compliance program files
OBL-025Review the Section 1557 language-access program: enforcement climate, source-translation availability, tagline procurement postureCompliance Officer45 CFR Part 92; PRV-004Review record, compliance program files
OBL-026Review service rates, with Clinical Director and Executive approvalClinical Director; Executive DirectorREG-003REG-003 revision; review record
OBL-027Renew business insurance: general liability, workers compensation, and cyber liability where heldExecutive DirectorCompany operationsPolicy declarations on file

Scheduled by plan or payer

ID Obligation Cadence Owner Source Evidence and location
OBL-028Audit claims coding and billing against documentationPer the annual compliance work planCompliance OfficerPOL-013; POL-004Audit reports to the Committee
OBL-029Complete payer revalidation and recredentialingPer payer scheduleExecutive DirectorPayer agreementsCredentialing records, payer correspondence

Event-driven

ID Obligation Trigger Owner Source Evidence and location
OBL-030Pre-hire exclusion screening for every candidateAt hireHuman ResourcesPOL-011Screening record
OBL-031CORI acknowledgment and check after the conditional offerAt hireHuman ResourcesPOL-017HRIS acknowledgment; iCORI record
OBL-032Complete the compliance onboarding set: onboarding training, TRN-002 acknowledgment, Code acknowledgment, conflict-of-interest disclosure, HR-001 with CFM-008, PFML notice, handbook receiptAt hireHuman Resources; Training CoordinatorTRN-001; TRN-002; COC-001; POL-009; HR-001; CFM-006HRIS e-sign records
OBL-033Complete the vendor trio: REG-002 row, pre-engagement exclusion screening, and a business associate agreement where the vendor handles PHIAt engagementDirector of Operations; Compliance OfficerPOL-005; POL-011; REG-002REG-002 row
OBL-034Revoke access to systems holding PHI or personal informationAt terminationPrivacy & Security Officer; Human Resources201 CMR 17.00Offboarding record, HRIS
OBL-035Communicate the change to affected workforce members and capture acknowledgment where requiredOn policy adoption or material revisionCompliance Officer; Training CoordinatorTRN-001Campaign and acknowledgment records
OBL-036Submit a conflict-of-interest disclosure within 10 business daysOn a change in circumstancesWorkforce member; Compliance OfficerPOL-009CFM-002 form; CFM-004 log

Realization

The register may be realized on paper, as an electronic document, or in the Company's compliance management system. Any realization carries every field defined here and references each obligation by its identifier.

Field contract. Each row defines: the identifier (OBL-NNN, stable for the life of the obligation, never reused); the obligation in one sentence; the cadence or trigger; the owning role or roles (role titles, per the Company's contact conventions); the governing source (document numbers or the legal authority); and the evidence artifact with its filing location, named by function.

Cadence and trigger vocabulary. Cadences are monthly, quarterly, annual, per the annual compliance work plan, or per payer schedule. A cadence may carry a binding window in its obligation text, such as within 60 days after the calendar year ends. Triggers are: at hire, at engagement, at termination, on policy adoption or material revision, and on a change in circumstances.

Division of labor with the compliance management system. This register defines the obligations. The compliance management system schedules them, records completions, and holds the evidence pointers. The system re-ingests the register at each approved revision, matching rows by identifier. A row retired here is closed there. A row added here is scheduled there. Conflicts resolve in favor of this register.

Retention

The register itself is a controlled document. Its revision history is its record.

Evidence artifacts retain under their governing documents: screening and exclusion records for at least six years (POL-011), compliance tickets and program files for six to ten years by issue type (POL-003), breach documentation for six years (POL-014), and personnel and acknowledgment records for the duration of employment plus the period their governing policy sets. Where no governing document states a period, completed-cycle evidence is retained for at least six years.